Red Notary & Tags Multiservice, Inc. v. DOT

Commonwealth Court of Pennsylvania·Decided August 3, 2026·No. 460 C.D. 2025·Unpublished·McCullough

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Red Notary & Tags Multiservice, Inc., :

Petitioner :

:

v. : No. 460 C.D. 2025 :

Department of Transportation, : Submitted: June 16, 2026 Respondent :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE McCULLOUGH FILED: August 3, 2026

Red Notary & Tags Multiservice, Inc. (Petitioner) petitions for review of the order entered by the Department of Transportation (Department) Executive Deputy Secretary of Transportation (Secretary) on March 12, 2025, denying its exceptions to a hearing officer’s (Hearing Officer) proposed report and order (Report and Order), and making the Report and Order, which revoked Petitioner’s certificate of authority (Certificate of Authority) issued pursuant to Agent Services Agreement No. 735293 (Agreement), final. After careful review, we affirm.

Background

The relevant facts and procedural history of this case are as follows. On August 1, 2016, Petitioner and the Department entered into the Agreement licensing Petitioner to provide vehicle title and registration services at its business located in Willow Grove, Pennsylvania. (Supplemental Reproduced Record (S.R.R.) at 1b.) The

Agreement was effective for an initial five-year term and was automatically renewable thereafter for five additional annual periods. Pursuant to the Agreement, the Department issued Petitioner a Certificate of Authority allowing it “to responsibly offer agent services to consumers in the Commonwealth, in a customer friendly manner, and in strict compliance with the terms and conditions of this Agreement and the Program Requirements [(Program Requirements)].” (S.R.R. at 3b, ¶ 3) (emphasis original).

The Agreement required Petitioner to obtain proof of identification from customers to complete transactions, stating that it “shall require that each applicant for title or registration provide, at the time of making application, proof of identification that complies with the Department’s proof of identification policies, and shall verify the authenticity of each applicant’s proof of identification document in the manner prescribed by the Program Requirements[.]” (S.R.R. at 4b, ¶ 9.) The Agreement incorporated a number of Program Requirements into its terms, attached to the Agreement as Exhibit “B,” which listed the following documents as acceptable forms of identification: “A valid Pennsylvania Photo Driver’s License; A valid Pennsylvania Photo Identification Card; A valid Pennsylvania Photo Exempt Driver’s License; A valid Pennsylvania Photo Exempt Identification Card; or A valid U.S. Armed Forces Common Access Card[.]” (S.R.R. at 21b, ¶ 1.7.)

The Agreement also permitted the Department to impose three varying levels of sanctions in the event Petitioner failed to comply with its terms. Specifically, the Agreement authorized the Department to suspend or revoke Petitioner’s Certificate of Authority, or to terminate the Agreement. (S.R.R. at 5b, ¶¶ 12-13.) Although the Agreement expressly defined the terms “Revocation” and “Suspension,” it did not define the word “Termination.”1

1 The definitional provision states in pertinent part:

(Footnote continued on next page…)

The Agreement authorized suspension or revocation of Petitioner’s Certificate of Authority under certain circumstances listed in Paragraph 12, including “for the acts and omissions listed in Paragraph 19” (listing 48 violations warranting revocation). (S.R.R. at 5b, ¶ 12a-c.) The penalty of termination is addressed in Paragraph 13 of the Agreement, which reads in pertinent part: “The Department may also terminate this Agreement for good cause shown, including, but not be limited to a Revocation of [Petitioner’s] [C]ertificate of [A]uthority[.]” (S.R.R. at 5b, ¶ 13a.)

On July 21, 2022, the Department conducted an administrative audit of Petitioner’s business and, based on the auditor’s findings, hand delivered a “Notice of Intent to Suspend Immediately” to Petitioner that same day (Suspension Notice). (S.R.R. at 24b.) The Suspension Notice advised Petitioner that the Department was suspending the Agreement, effective immediately, due to Petitioner’s acceptance of passports from other countries for vehicle registrations, in violation of Paragraph 19(2) of the Agreement. On September 9, 2022, the Department sent Petitioner a “Notice of Intent to Terminate,” advising Petitioner of its intent to terminate the Agreement

Revocation--A sanction which permanently withdraws [Petitioner’s] certificate of authorization.

Suspension--A sanction which temporarily withdraws [Petitioner’s] certificate of authorization to provide agent services.

(S.R.R. at 3b, ¶ 2.)

effective October 22, 2022, based on Petitioner’s violations of Paragraphs 19(2) and 19(4)2 of the Agreement (Termination Notice).3 (S.R.R. at 25b-27b).

On September 28, 2022, Petitioner filed an appeal requesting a hearing, as well as an unopposed motion for supersedeas. The Hearing Officer granted the motion for supersedeas and held a hearing on the matter on February 8, 2023. At the hearing, Petitioner’s owner, Jenny Pena, testified that the company had never been cited for any violations in the past. Ms. Pena averred that it has always been her intention to obtain proper identification and documentation from customers before completing any transaction. (R.R. at 25-26a.) The Hearing Officer took the case under advisement pending the parties’ submission of briefs.

In its post-hearing brief, Petitioner contended the Department lacked the authority to terminate the Agreement, because the relevant provisions of Paragraph 19 of the Agreement (Paragraph 19) authorized only the less serious sanction of revocation of the Petitioner’s Certificate of Authority. (R.R. (Reproduced Record) at 61a.) Petitioner maintained that despite the Agreement’s clear use of the separate words “revocation” and “termination,” along with corresponding circumstances warranting each respective sanction, the Department improperly conflated the terms in issuing the Termination Notice. Petitioner also argued the Department violated its due process rights by failing to hold a hearing before it imposed any sanction because it

2 Paragraph 19(2) of the Agreement authorizes revocation of Petitioner’s Certificate of Authority if it “has accepted proof of identification documents which fail to conform to Department guidelines in connection with issuance of the registration cards or plates - first violation.” (S.R.R. at 13b, ¶ 19(2).) Paragraph 19(4) provides that revocation of the Certificate of Authority is warranted if Petitioner “has processed applications or issued registration cards or plates without proper documentation as required by the Department-first violation.” (S.R.R. at 14b, ¶ 19(4).)

3 The Termination Notice also advised that suspension of Petitioner’s Certificate of Authority was warranted for one month because of multiple errors found during the audit. (S.R.R. at 26b.)

“could have determined that mitigating circumstances existed such that these first offense charges should not have resulted in what might be considered a lifetime ban.” (R.R. at 62a.)

The Department countered:

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